Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
Disallowance of alleged bogus purchases/unexplained expenditure under s. 37 was held unsustainable where the AO relied solely on a third-party's subsequently retracted statement alleging invoice accommodation without delivery, without confronting or rebutting the assessee's documentary evidence. As the assessee produced recorded materials substantiating the expenditure and there was no finding of any actual purchases from the alleged biller (the group being only a transporter), and no corroborative material supporting the statement, a statement alone could not justify the addition. The disallowance was therefore deleted and the appeal of the revenue failed. - ITAT
Disallowance of alleged bogus purchases/unexplained expenditure under s. 37 was held unsustainable where the AO relied solely on a third-party's subsequently retracted statement alleging invoice accommodation without delivery, without confronting or rebutting the assessee's documentary evidence. As the assessee produced recorded materials substantiating the expenditure and there was no finding of any actual purchases from the alleged biller (the group being only a transporter), and no corroborative material supporting the statement, a statement alone could not justify the addition. The disallowance was therefore deleted and the appeal of the revenue failed. - ITAT
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